Requesting a waiver of the penalty is only necessary when the RMD is late. In your case, no 2018 Form 5329 requesting a penalty waiver would have been necessary had you completed the RMD by April 1, 2019. If you inadvertently already filed 2018 From 5329 Part IX requesting waiver of the excess accumulation penalty on the amount of your late (after April 1) 2018 RMD, there is no need to do so again.
